On behalf of the German and European Rubber Industry we ask to NOT extend CBAM to polymers and organic chemicals. We are representing 220 companies, producing a wide range of industrial products within the EU, elastomers and organic chemicals being their core material. All European mobility, the construction sector, baby- and healthcare, food production as well as drinking water supply relies on our products.
WDK
Wirtschaftsverband der deutschen Kautschukindustrie e. V.
Industry association · Germany · EU Transparency Register 847583214230-94
4
positions filed
in the 326 files tracked
4
legislative files
of 326 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1205 trade and business associations on this site, they rank #439 by legislative files engaged — a count of participation, not a measure of influence.
0.6
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2014
in the register since
Declares membership of
- European Tyre and Rim Technical Organisation (www.etrto.org/Home)
- Global Platform for Sustainable Natural Rubber (www.gpsnr.org)
- International Rubber Study Group (www.rubberstudy.org)
- Arbeitsgemeinschaft Zulieferindustrie (https://argez.de/)
- Bündnis faire Energiewende (www.faire-energiewende.de/)
- Initiative pro AGB-Recht (http://www.pro-agb-recht.de/)
- Europäische Bewegung Deutschland (https://www.netzwerk-ebd.de/)
- Inititiative Fair Rubber e.V. (https://fairrubber.org/de/)
- Rabber Traders Association of Europe(www.rtae.org)
- International Institute of Synthetic Rubber Producers (iisrp.com)
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Trade and business associations
- Registered as
- Wirtschaftsverband der deutschen Kautschukindustrie e.V. (wdk)
- Head office
- Frankfurt/Main, Germany
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Wirtschaftsverband der deutschen Kautschukindustrie e. V. filed 4 positions between 7 Oct 2022 and 5 Dec 2025, across 4 of the 326 legislative files tracked here, attaching a full position paper 3 times.
2022 · 1 filed2025 · 3 filed
What they argued
The German Rubber Manufacturers Association welcomes the approach to amend annex I of the regulation (EU) 2023/1115 to clarify existing ambiguities in the regulation in a legally binding manner and to introduce technical fixes to address its unintended negative effects on the sustainable use of resources. However, adjustments will have to be made to the draft amendment of annex I to achieve this.
he German Rubber Manufacturers Association wdk welcomes the opportunity to provide feedback on the initiative on the planned Advanced Materials Act. Rubbers and elastomers are materials that are essential for components that are indispensable for various sustainable and critical technologies. Rubber and elastomer materials are designed to meet the specific requirements of their respective application.
The Wdk supports the European Commission’s Chemicals Strategy for Sustainability and welcomes its intention to consolidate chemicals regulation both between different regulations, such as REACH and the Drinking Water Directive, and between Member States.
Filed in German · English published by the European Commission
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- Cefic · 4 files in common
- German Association of Biotechnology Industries (DIB) within the German Chemical Industry Association - VCI · 4 files in common
- Japan Business Council in Europe · 3 files in common
- ACEA · 3 files in common
- BASF SE · 3 files in common
Showing 5 of 28.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.